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[email protected] New York, NY 10017 Rule 14a-8(e)(2) January 15, 2021 BY ELECTRONIC MAIL Office of Chief Counsel Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Via email:
[email protected] Re: Tribune Publishing Company – Shareholder Proposal Submitted by TNG-CWA Local 34071 Ladies and Gentlemen: On behalf of Tribune Publishing Company, a Delaware corporation (the “Company”), we are submitting this letter pursuant to Rule 14a-8(j) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to notify the Securities and Exchange Commission (the “Commission”) of the Company’s intention to exclude from its proxy materials for its 2021 annual meeting of shareholders (the “2021 proxy materials”) a shareholder proposal and statement in support thereof (the “Proposal”) submitted by TNG-CWA Local 34071 (the “Proponent”). We also request confirmation that the Staff of the Division of Corporation Finance (the “Staff”) will not recommend to the Commission that enforcement action be taken if the Company omits the Proposal from its 2021 proxy materials for the reasons discussed below. A copy of the Proposal and related correspondence from the Proponent is attached hereto as Exhibit A. In accordance with Staff Legal Bulletin No. 14D (Nov. 7, 2008) (“SLB No. 14D”), this letter and its exhibits are being delivered by e-mail to
[email protected].